We respectfully submit comments in response to the request for information, “Drafting a New Federal Strategy to Reduce Childhood Lead Exposures and Impacts.” We commend the President’s Task Force on Environmental Health Risks and Safety Risks to Children (Task Force) for its commitment to developing strategies to protect children from environmental health risks and appreciate the opportunity to comment. The undersigned organizations advocate for policies to ensure individuals, families and communities have access to safe and healthy homes, including prevention against lead poisoning that results in devastating and permanent harm. Some of the undersigned organizations represent families and communities exposed to lead poisoning in East Chicago, Indiana, Flint, Michigan, and countless cities and states across the United States. Others have members concerned with the ongoing impacts of lead poisoning and work on policy solutions to ensure children are not exposed to lead in their homes and communities. With that knowledge in mind, we urge you to swiftly develop a comprehensive federal strategy to eliminate lead from children’s environments. At a minimum, the strategy must set as the first priority primary prevention practices to eliminate legacy lead, halt the current use of lead, and prohibit industrial processes that contaminate the environment with lead. The following recommendations focus on 1) priority risks and goals, 2) strategy development and implementation, and 3) messaging and outreach.
In addition, we support and incorporate by reference responses to this Request for Information from EarthJustice and Green & Healthy Homes Initiative and direct the Task Force to the following previously submitted comments for additional recommendations:
- Comments to Notice of Demonstration to Test Proposed New Method of Assessing the Physical Conditions of Voucher-Assisted Housing, 24 CFR Part 982, Docket No. FR- 5928-N-01, July 5, 2016 (submitted by Health Justice Project, Sargent Shriver National Center on Poverty Law, National Housing Law Project)
- Comments to “Reducing Regulatory Burden; Enforcing the Regulatory Reform Agenda Under Executive Order 13777,” Docket No. HUD-FR-6030-N-01, June 14, 2017 (submitted by Green & Healthy Homes Initiative, National Center for Healthy Housing, Environmental Defense Fund, Earthjustice, Sargent Shriver National Center on Poverty Law, National Low-Income Housing Coalition, Housing Justice Network, and National Housing Law Project, Health Justice Project, and many of the undersigned organizations)
- Comments regarding U.S. Environmental Protection Agency’s Response to Executive Order 13777, “Enforcing the Regulatory Reform Agenda,” Docket No. EPA-HQ-OA- 2017-0190-0042, May 12, 2017 (submitted by Environmental Defense Fund, Health Justice Project, Green & Healthy Homes Initiative, Sargent Shriver National Center on Poverty Law, Earthjustice)
- Comments on Proposed Rule “Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards in Federally Owned Residential Property and Housing Receiving Federal Assistance; Response to Elevated Blood Lead Levels” (Docket No. FR-5816-P-01), October 31, 2016 (submitted by Environmental Defense Fund, Green & Healthy Homes Initiative, National Center for Healthy Housing, Sargent Shriver National Center on Poverty Law, Health Justice Project, National Housing Law Project, EarthJustice, Environmental Defense Fund, National Housing Law Project)
- October 2016 Letter to the President’s Task Force on Environmental Health and Safety Risks to Children from over forty nonprofit and advocacy organizations regarding a plan of action to prevent childhood lead exposure
PRIORITY RISKS AND GOALS
We urge the Task Force to address all priority risks, including sources of lead exposure from housing, air, water, soil, food, and environment, in the new federal lead strategy. We provide recommendations for addressing each of these risks and the obligations of numerous federal agencies herein.
STRATEGY DEVELOPMENT AND IMPLEMENTATION
I. The Task Force must emphasize primary prevention as a critical strategy to protecting children from the permanent effects of lead poisoning.
Lead is a neurotoxin with no known safe level of human exposure that presents an urgent health and safety threat to children.1 Lead poisoning causes irreversible neurological harm and results in numerous and severe morbidities, such as significant biological and neurological damage affecting cognition, behavior, bodily functions, growth, and development.2 It can lead to academic failure, juvenile delinquency, high blood pressure, brain damage, learning disabilities, behavioral problems, developmental delay, and even death.3 There is no safe level of lead poisoning4 and the devastating harm that lead causes to children, especially in neurological development, is well documented.5 Negative health effects can occur at even the lowest
detectable concentrations of lead in blood in children of any age.6 Even at low levels of exposure, it can lead to brain damage, reduced IQ, diminished intellectual and academic abilities, academic failure, juvenile delinquency, developmental delay, and learning disabilities.7 At blood lead levels beginning as low as 1 μg/dL, there is a negative slope relating to blood lead level and IQ.8 An increase in blood lead level from 1 μg/dL to 4 μg/dL is associated with a reduction in mean IQ of approximately 2.3 to 5.2 IQ points.9 At a blood lead level of 3 μg/dL, children demonstrate decreased end of grade test scores; at a blood lead level of 4 μg/dL, three-year-olds face an increased likelihood of being classified as learning disabled in elementary school; and at a blood lead level of 5 μg/dL, children are thirty percent more likely to fail third grade reading and math tests and to be non-proficient in math, science, and reading.10 Lead poisoning has an adverse effect on most major bodily systems, including the cardiovascular, reproductive, immune, nervous, digestive, kidney, and renal systems.11 As a result, lead poisoning causes severe and permanent biological and neurological damage that affects cognition, behavior, bodily functions, growth, and development. These negative health effects thwart a child’s ability to thrive and access opportunity in the future. Lead can accumulate in human bone tissue, where it can reenter